ML20210V102
| ML20210V102 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 09/12/1997 |
| From: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20046D783 | List: |
| References | |
| AW-97-1169, NUDOCS 9709230033 | |
| Download: ML20210V102 (14) | |
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Westinghouse Energy Systems g3j5 Electric Corporation AW 971169 September 12,1997 Document Control Desk
'U.S. Nuclear Regulatory Commissiou Washington, DC 20$55 NITENTION:
MR. T. R. QUAY APPL.lCATION FOR WITilllOLDING PROPRIETARY INIORM AllON FROM PUllLIC DISCLOSURE SUlijECT:
RilSPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON AP600 NOTRUMP VERIFICATION AND VALIDATION (RAI 440.721a)
Dear Mr. Quay:
The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")
pursuant to the provisions of paragraph (b)(1) of Section 2.790 of tl e Commission's regulations. It contains commercial strategic infbunation proprietary to Westinghouse and customarily held in confidence The proprietary material for whicn withholding is being requested is identified in the proprietary version of the snbject report. In conformance with 10CFR Section 2.790, Aflidavit AW 97 Il69 accomf anies thi:: application for withhelding setting fort i the basis on which the identified proprietary t
information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information which la proprictury to Westinghouse be witi held from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-971169 and should be addressed to the undersigned.
Very truly yours, A
[f firian A. McIntyre, Manager Advanced Plant Safety und Licensing jml cc:
Kevin llohrer NRC OWFN - MS 12E20 9709230033 970912" PDR ADOCK 05200003 A
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AW.97 Il69 j
- COMMONWEALTil OF PENNSYLVANIA:
ss COUN1Y OF ALLEGilENY:
Before me, the undersigned authority, personally appeared Brian A. McIntyre, who, being by me -
duly sworn according to law, deposes and says that he is authorlied to execute this Amdavit on behall' of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Amdavit are true and correct to the best of his knowledge, infonnation, and belief:
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Brian A. McIntyre, Manager Advanced Plant Ssfety and Licensing Sworn to and subscribed before me is 144 day sM h.1997 of NoWW Seal Janet A. Schwab, Notary Pu%c N N U N MS PI b
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AW.971169
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(1)
I am Manager, Adsanced Plant Safety And 1.icensing, in the Nuclear Projects Division, of the
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' Westinghouse filectric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply fbr its withholding on behalf of the Westinghouse Energy Systems ilusiness Unit.
(2)
I am making this AfliJavit in conformance with the provisions of 10CI'R Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utillred by the Westinghouse Energy Systems ilusiness Unit in designating information as a trade secret, privileged or as coni'idential commercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.'t90 of the Commission's regulations, the following is furnished fbr consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)
The infbrmation sought to be withheld from public disclosure is owned and has been held in confidence t y Westinghouse.
(ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types ofinfonnation customarily held in confidence by i and, in that connection, t
utilizes a system to determine when and whether to hold certain types of infbrmation in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, inibrmation is held in confidence ifit falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
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AW.971169 l
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'ihe information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of S
Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)-
It consists of supporting data. including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved -
marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, l
assurance of quality, or licensing a similar product.
l (d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
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(e)
It reveals aspects of past, present, or future Westinghouse or customer funded i
j development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a)
The use of such information by Westinghouse gives Westinghouse a i
l competitive advantage over its competitors, it is, therefore, withheld from disclosure to protect the Westinghouse competitive position. -
i (b)
It is information which is marketable in many ways. The extent to which such p-information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
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AW.971169 (c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary infonnation pertinent to a particuw competitive advantage is potentially as valuable as the total competitive advantage if competitors acquire components of proprietary information, any one component may be the key to the entire puule, thereby depriving Westinghouse of a competitive advantage.
(c)
Unrestricted disclosure would jeopaWire the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f) 1hc Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
'ihe information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge mid belief.
(v)
Enclosed is Letter DCP/NRC1028 (NSD-NRC-97 5318), September 12,1997, being transmitted by Westinghouse Electric Corporation @) letter and Application Ibr Withholding proprietary information from Public Disclosure, lirian A. McIntyre @),
to Mr. T. R. Quay, Ollice of NRR The proprietary infonnation as submitted for use by Westinghouse Electric Corporation is in response to ques' ions concerning the AP600 plant and the associated design certification application and is expected ?o be l
applicable in other licensee submittals in response to certain NRC requirements for i
justification oflicensing advanced nuclear power plant designs.
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AW.971169 4
This information is part of that which will enable Westinghouse to:
I (a)
Demon 6trate the design and safety of the AP600 Passive Safety Systems.
t (b)
Establish applicable verincation testing methods.
(c)
Design Advanced Nuclear Power Plants that meet NRC requirements.
(d)
Estabilsh technical and lleensing approaches for the AP600 that will ultimately result in a certined design.
(e)
Assist customers in obtaining NRC approval for future plants.
Fur *her this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar information to its customers foi purposes of meeting NRC requirements for advanced plant Ilcenses.
(b)
Westinghouse can sell support and defense of the technology to its customers in the licensing process.
l'ublic disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar advanced nuclear power designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the infonnation would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information, i
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AW.971169
'the development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order Ibr competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not.
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4 ENCLOSURE 2 TO DCP/NRC1028 NON PROPRIETARY VERSION OF RAI 440,721(a)
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I Question 440.721 (OITS $646)
(at Provide additional esplanation and significance of the consistent delay in NOTRUMP predicted commencement of CMT draining when compared to testing data. What is the significance of NOTRUMP's lack of a Hashing model in failing to accurately predict start of CMT draindown.
Resp <mset NOTRUMP's consistent delay in the prediction of the onset of CMT draining i. due to two factors:
M in n.ast of the SPES and OSU tests, the CMT's begin to drain when sufficient mass has been depleted to drain the stearn generator tubes and begin to drain the cold legs. Vapor then flows up the balance line, displacing hquid and causing the CMT to dram. NOTRUMP, in $cveral tests, predicted a slower stearn generator draining and initiation of vapor formation in the cold legs, in addition, while in the CMT test draining was observed soon after vapor entered the balance line, draining was not predicted in NOTRUMP until the upper volume of the CMT reached saturation temperature. floth factors led to consistent late prediction of CMT drain by NOTRUMP.
b)
In some of the OSU tests, the CMTs began to drain before the steam generators drained (see below).
This is due to dashing of the hquid at the top of the balance line when the saturation temperature decreases to the liquid temperatu e. NOTRUMP did predict this mode of draining in some cases initially. For these cases, the CMT only slightly drained, and did not begin free drain until significant vapor began to enter the balance line.
Figures 440.72ia 1 and 440.728a 2 show the Guid temperature and the saturation temperature at the top of the balance line and sescral elevations in the CMT for SPES test S00303 (2 inch cold leg break), respectively.
Figuie 440.721a 3 compares the collapsed liquid levels in the steam generator tubes, the CMT balance line, and the CMT. The Guid remains subcooled, and the CMT does not begin to drain, until the balance ime begins to dram at about 550 seconds. For this test. CMT draining does not begin until the steam generators drain and the cold legs begin to fill with vapor. His xcurred in all the SPES tesa. In contrast, in some of the OSU tests the CMT began to drain before the steam generators and cold legs drained. Figure 440.72ia-4 shows the collapsed lesels in the steam generator, balance line, and CMT for OSU test SBIR (2 inch cold leg break). The steam generator has not completely drained before evidence of sapor is seen in the balance kne. and the CMT begins to dram at about 120 seconds.
Figure 440.721 1 indicates that the difference between Guid temperature and Tsat at the top of the balance line can be quite small. Small inaccuracies in predicted system pressure could therefore be sulficient to initiate or present draining by this mechanism. The small difference also mdicates that in the AP600 flashing of the balance line cannot be precluded (and for the smaller breaks is calculated). As in the test simulations, however, this mechenism does not initiate contmuous draining because the mitial temperature of the liquid in the t>alance hne is well below the cold leg temperature (approximately 400*F), and the liquid at the top of the balance line at the CMT entrance is close to the CMT temperature (ie, highly subcooled relative to Tsat), and therefore the
' amount of steam generated is small. The implications for NOTRUMP's application to AP600 are as follows:
NOTRUMP does not contain a nonequihbrium Dashing model. If the liquid remains slightly subcooled relative W westinghouse
NC bl40tSTFetAttm MAL afMitatttel to the local saturation temperature, s apor will not be formed; therefore CMT draining will be delayed. On the other hand, the hquid cannot becorne superheated relative to the saturation temperature either. One scenarm which has been suggested is that the liquid may remain superheated relatise to Tsat. His metastable condition can be maintained, it is argued, to significant superheat lesels because the cold piping walls do not provide nucleation sites. The liquid will therefore not Cash in the plant or test facility when predicted to do so by NOTRUMP. NOTRUMP would then predict early CMT draming for this scenarm. Howeser, heated walls are not necessary for the production of nucleation sites; minute particles or contaminants in the Guid are also sufficient to initiate Dashing. Even in the presence of cold walls and extreme care in water purity, metastable states of liquid water cannot be sustained beyond a few degrees above saturation (Reference 440.721a l, page 1311). There is no measured evidence of significant and sustained liquid superheat in any of the tests, in ar,ldition, assumig, that such a state occurs, the RCS will contmue to depressurire due to heat removal by the steam generators (which base not begun to drain yeti and by the PRHR, as well as mass removal by the break.
As a result, the saturation temperature will soon fall sufficiently below the liquid temperature to induce Dashing.
it is concluded that a prolonged rnetastable state is not likely, and there is no need to include a model to predict such a state in NOTRUMP.
References.
440.72la 1 Collier, L O., Conmutt_Driling and Condensauna. Third Ed., Clarendon press,1994.
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Figure 440.721a l Ruid temperature in the balance line for SPES test S00303 "N
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Figure 440.72ia 3 Collapsed liquid levels in the steam generator (LSGBH), balance line, and CMT for SPES test S00303.
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Figure 440.721a-4 Collapsed liquid levels in the steam seurator, balance line, and CMT for OSU test S818.
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